Heart of Atlanta Motel v. United States (1964)

Background

• Landmark civil rights dispute involving the Heart of Atlanta Motel.
• Central issue: Use of Congress's Commerce Clause powers to protect civil rights.

Civil Rights Act of 1964

• Prohibits discrimination based on race in places of public accommodation (e.g., motels, restaurants).
• Enacted by Congress to address racial discrimination.

Case Details

• The Heart of Atlanta Motel:
  • Located in Atlanta.
  • Advertised in national media.
  • Positioned near interstate highways.
  • 75% of business came from out-of-state guests.
  • Refused to rent rooms to African Americans.
• The motel challenged the constitutionality of the Civil Rights Act, claiming:
  • Congress exceeded its constitutional authority.
  • The Act violated the motel's due process rights.

District Court Ruling

• Upheld the Civil Rights Act as constitutional under the Commerce Clause.
• Prohibited the motel from discriminating against African Americans.

Supreme Court Ruling

• Issue: Can Congress prohibit racial discrimination by places of public accommodation using its Commerce Clause authority?
• Held: Congress can enact laws to prevent racially discriminatory policies in hotels serving interstate travelers.
  • These policies affect interstate commerce significantly.

Key Points from the Supreme Court

• Congress's power to regulate interstate commerce includes regulating local commerce incidents affecting interstate goods flow.
• Racial discrimination disrupts interstate travel and discourages African American travel, hindering interstate commerce.
• The Civil Rights Act is a valid exercise of Congress’s Commerce Clause authority.

Concurring Opinions

Justice Black

• Agreed with the use of the Commerce Clause.
• Emphasized the motel's advertisement on interstate highways and its impact on interstate commerce.
• Rejected the due process violation claim, noting regulation of private property isn’t a constitutional taking.
• The Fourteenth Amendment prevents using it to strip Congress's power to protect against discrimination.

Justice Douglas

• Argued against solely using the Commerce Clause.
• Suggested broader authority under Section 5 of the 14th Amendment:
  • Grants Congress power to enforce equal protection of law.

Justice Goldberg

• Supported basing the decision on both the 14th Amendment and the Commerce Clause.
• Asserted Congress's authority under both provisions for enacting the Civil Rights Act.

Significance

• A landmark decision allowing Congress to use its Commerce Clause powers to combat racial discrimination.